The 409a isn't based on what the market will pay since private shares aren't on the stock market. It's a guess about what the market might pay, but since the sh

The 409a isn't based on what the market will pay since private shares aren't on the stock market. It's a guess about what the market might pay, but since the shares aren't liquid, the guess can't be tested, so there is huge leeway to pick a favorable number.